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FCOI Annual Disclosure period:

September is the annual disclosure period. Please update your disclosure any time from September 1-30 at the following link: Statement of Financial Interest.

POLICY UPDATE

The University of Alabama has revised the Policy on Conflict of Interest/Financial Disclosure in Research and Other Sponsored Programs as required by changes in the federal regulations 42 C.F.R. Part 50, Subpart F (grants and cooperative agreements) and 45 C.F.R. Part 94 (contracts). The revised policy is effective as of August 24, 2012.

What is a conflict of interest?

The University of Alabama (UA) realizes that actual or potential conflicts of interest may occur in the normal course of research and other sponsored activities at a vibrant university. They are inevitable, and do not necessarily represent any impropriety by employees if disclosed and properly managed. The key to identifying a conflict of interest is to evaluate whether there is a potential for improper personal gain or influence resulting from the dual roles the employee plays. Perceived conflicts of interest can be as harmful as real conflicts of interest. Therefore, it is UA's policy that outside interests of an investigator should be reported. The Office for Research Compliance will review the disclosures and inform the investigator if they feel there is a potential risk that needs further management.

What does the Conflict of Interest Committee do?

The University Conflict of Interest Committee serves as a resource with respect to matters involving conflicts of interest and the identification, - management, mitigation, or elimination of specific conflicts of interest. The committee will work with the investigators and Research Compliance Officer to resolve potential or apparent conflicts of interest by implementing reasonable controls which are commensurate with the potential for conflict. The committee will also provide oversight for implementation of the Policy on Conflict of Interest/Financial Disclosure in Research and Other Sponsored Programs and recommend to the Vice President for Research and Provost all future changes/modifications to the Policy.

UCIC Meeting Dates

  • November 16, 2016
  • January 18, 2017
  • March 22, 2017
  • May 17, 2017
  • July 19, 2017
  • September 20, 2017
  • November 15, 2017

UCIC Member Login

Who must file a disclosure?

Anyone who is responsible for the design, conduct, or reporting of federally-funded research, regardless of his/her title or role on the project or the receipt of funding must submit a disclosure. This definition includes adjunct faculty, students, volunteers, subcontractors, consultants, collaborators, research coordinators, research assistants, and other research staff.

When will I need to submit my disclosure?

  • Any new researchers are required to submit an FCOI disclosure at the time of submission of proposals for any federal funding.
  • All existing researchers are required to renew their FCOI during the annual disclosure period, currently September 1st - 30th.
  • All researchers are required to submit an updated FCOI disclosure immediately as changes occur.
What happens if I don’t complete my annual disclosure?
  • Grant proposals and contracts may not be submitted if you are listed as personnel
  • Funds from grant or other sponsored program awards will not be distributed;
  • IRB and IACUC will not release the final letter of approval;
  • Other disciplinary action as required by federal regulation; and
  • The granting or sponsoring agency will be notified, if applicable.

 

UA POLICY ON FCOI

The University has developed this policy relating to conflicts of interest applicable to all UA investigators and the policy applies to all sponsored programs, including federal, state, and local government; industry; or not-for-profit sponsors. The policy also covers UA intellectual property licensed to an entity in which a UA investigator owns an interest or serves as an employee, officer, or member of the Board of Directors regardless of the source of funding. The policy is to be administered in conjunction with laws and policies setting forth standards of conduct including Title 42 Code of Federal Regulations (CFR) Part 50, Subpart F; Title 45 CFR Part 94; the Ethics Act of the State of Alabama; and University of Alabama Faculty Handbook, Appendix E, On Preventing Conflicts of Interest in Government-Sponsored Research at Universities.

Download: FCOI Policy

Frequently Asked Questions

Download: FAQs

Disclosure

Submit Online: STATEMENT OF FINANCIAL INTEREST

Training

Conflict of Interest (COI) training is required once every 4 years and should be completed by each investigator prior to engaging in any research or sponsored activity related to a funded grant or contract (refer to Section III. D. of the Policy on Conflict of Interest).

COI training is now available through the CITI Program. COI training will no longer be offered via the Formstack-hosted Conflict of Interest Training & Certification form and online NIH tutorial.

Instructions to enroll in the new COI course:

1. Log into CITI via one of the following options:

  • myBama CITI single sign-on at myBama CITI Login Portal (This option is only for UA faculty, staff, and students with an active myBama account.)
  • CITI website at www.citiprogram.org. Please note that your CITI account must be affiliated with UA. If you are not currently affiliated with UA, from the Main Menu select “Click here to affiliate with another institution” and enter (or search for) “University of Alabama”.

2. From the Main Menu, click “University of Alabama Courses”

3. Under My Learner Tools for University of Alabama, click “Add a Course or Update Learner Groups”

4. On the Select Curriculum page, scroll down to the last question (# 8: Conflicts of Interest), select “Yes” and click “Submit”

The CITI “Conflicts of Interest” course consists of a brief introduction and 5 modules.

If you have already completed the COI training, you will not be required to complete the new CITI COI course until your training expires 4 years from the date of initial completion. You will receive an email notification to renew your COI training prior to expiration.

 

FEDERAL REGULATIONS PERTAINING TO CONFLICT OF INTEREST

Public Health Service Regulations
Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50. Subpart F) Responsible Prospective Contractors (45 C.F.R. Part 94)

NSF Regulations
Download: Guidance for Financial Conflict of Interest

FDA Regulations
Download: FDA Guidance - Financial Disclosure by Clinical Investigators

Who should I contact for assistance with a conflict of interest issue?

Tanta Myles
Director – Office for Research Compliance
cmyles@research.ua.edu
(205) 348-5746

Mukesha Voltz
Research Compliance Specialist
mvoltz@research.ua.edu
(205) 348-6638

 

To request information regarding identified financial conflicts of interest held by UA investigators, please submit a written request, including the investigator’s name and project title, to the following address:
              
Office for Research Compliance
The University of Alabama
Box 870127
Tuscaloosa, AL 35487-0127

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